Privacy Policy

1. Collection of Personal Information

For purposes of this Privacy Policy, “personal information” means any information that relates to an identified or identifiable individual, exclusive of PHI as discussed above. The personal information we collect through our Sites will be apparent by the context of the page, and may include the following types of information.

a. Personal Information You Provide to Us

We may collect personal information about you when you register with us for a Millie account, when you use our Services, when you participate in surveys or promotional activities, give us feedback, or when you otherwise choose to provide your information to us.

• Registration and account information.  When you sign up for a Millie account, or otherwise request our Services, you may be asked to provide certain personal information including your first and last name, phone number, and email address.  
• Service-related information and promotions.  In the course of receiving services, you may be asked to provide other information such as audio (with your permission), photos and videos (with your permission) etc., and/or request access to your microphone or camera in order to verify your identity and provide Services to you.  In addition, we may invite our users to participate in surveys or similar promotions, which may involve the collection of your first and last name and email address.
• Profile and demographic information.  In connection with registration or other interaction with our Sites and Services, you may be asked for, or provided to opportunity to provide, additional information about yourself including your race, ethnicity, job title, birth date, sex, and gender identification, together with other information such as occupation and personal interests.  
• Communications information. When you communicate with us through our Sites, including through use of our synchronous communication and telehealth communication services, we may collect your first and last name, email address, and any personal information that you choose to provide in the content of your message.
• Payment information.  If you sign up for a paid product or service from us, you may be required to provide your payment card or bank account information.  We may also ask you for your income or other financial information to determine eligibility for certain programs and incentives.

b. Information That We Automatically Collect

Our Sites may use cookies and other tracking technologies such as web beacons, embedded scripts, and tags (“Cookies”), which collect information from you automatically as you use our Sites, including:

• Browser and device data, such as IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, location information, and the language version of the Sites you are visiting; and
• Usage data, such as browsing history, time spent on the Sites, pages visited, links clicked, language preferences, patterns of use, and the pages that led or referred you to our Site.

We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services.  For example, we use Google Analytics on our Sites to help us analyze your use of our Sites and diagnose technical issues.

Please review our Cookie Policy below for more information about our use of these technologies.

c. Information from Our Partners

We may receive your Personal Information from our partners, such as a referring provider or device integration partner, in connection with one or more business purposes, including to make our Services available to you.

d. Aggregated, anonymized, and deidentified information

We may create aggregated, anonymous or de-identified data from personal information by removing data components that make the data personally identifiable to you or through obfuscation or other means. Our use of aggregated, anonymized and de-identified data is not subject to this Privacy Policy and may be further controlled by federal health privacy law as outlined in our Notice of Privacy Practices.

2. Use of Personal Information

We use the personal information we collect to provide, maintain, and improve our Sites and Services. These uses include: 

• Providing you with requested Services, including the delivery of our healthcare services, insurance claim submission, and providing you with information and other services related to your health and wellness
• Providing you with customer service and support, and to facilitate other communications that you request or that are required to render Services to you
• Providing you with information about new Services and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalize, measure, and improve such offers
• Performing analytics for new and existing Sites and Services, such as our user accounts and related features
• Personalizing, maintaining, and improving the quality of our Sites and Services
• Growing our business, including performing research and development, understanding our user trends, and understanding the effectiveness of our marketing
• Protecting ourselves, you, and others; preventing fraud; and creating and maintaining a trusted, secure, and reliable online environment
• Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the users of our Sites or Services is among the assets transferred
• Complying with our legal obligations; respond to subpoenas, court orders, or legal process; or to establish or exercise our legal rights or defense against legal claims
  

3. Sharing of Personal Information

We may share your personal information with the following categories of third parties:

1. Our affiliates.  We may share personal information with our affiliates, in which case, we will require such affiliates to comply with the terms of this Privacy Policy.
2. Service providers.  We share personal information with our service providers to provide services on our behalf, such as payment processing, analytics, advertising, hosting, marketing, customer and technical support, and other services. 
3. Third party providers, plans, and institutional partners.  We may share personal information with third-party partners in connection with our Site and Services, including your care providers, health insurers, and/or our other institutional partners.  
4. Third-party platform advertising.  We may share your information with third-party platform providers who assist us in serving advertising regarding the Sites and Services to others who may be interested.  We also partner with third parties (such as Facebook and Google) who use Cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location and/or interests.
5. Affiliate and business transfer.  If Millie is involved in a merger, acquisition or asset sale, your personal information may be shared or transferred in connection therewith.
6. Compliance and harm prevention.  We may share personal information as we believe necessary (i) to comply with applicable law, rules and regulations; (ii) to enforce our contractual rights; (iii) to investigate possible wrongdoing in connection with the Site and Services; (iv) to protect and defend the rights, privacy, safety and property of Millie, you or others; and (v) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
   

4. Your Rights and Choices

You may have rights and choices regarding our use and disclosure of your personal information.  Unless instructed otherwise, you can exercise these rights and choices using the information in the Contact Us section at the end of this Privacy Policy.  Please note that you may have further rights and choices as may be described in our Notice of Privacy Practices.

1. Opting out of receiving electronic communications from us. You will not receive promotional electronic communications from us unless you have opted in to receive such communications. If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails or by contacting us at privacy@millieclinic.com.  We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required in order to provide you with our Services or for other reasons disclosed in this Policy.
2. View or change your account personal information.  If you have an account on our App, please visit your account for any privacy rights, choices, or preference options that may be offered.  We also encourage you to consult our Notice of Privacy Practices for more information about your privacy rights. 
3. Your California privacy rights.  If you are a California resident, you may visit our California Privacy Notice to learn more about the personal information we collect, use and disclose, as well as your privacy rights related to your personal information under the California Consumer Privacy Act (CCPA) and other California state laws.
4. Your Nevada privacy rights.  Nevada residents have the right to request to opt out of any “sale” of their personal information under Nevada SB 220.  We do not currently sell personal information under Nevada law; however, you may still request to opt out of the future sale of your personal information.  If you are a Nevada resident and would like to make such a request, please contact us using the information in the Contact Us section at the end of this Privacy Policy, and provide “Nevada Privacy Rights” in the subject line.  You must include your full name, email address and postal address in your request so that we can verify your Nevada residence and respond.  In the event we sell your personal information after the receipt of your request, we will make reasonable efforts to comply with such request.
   

5. Data Security

The security of your personal information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.  We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, disclosure or misuse.  We encourage you to secure your account with a strong and regularly changed password, and to keep your password private.

6. Cookie Policy

When you visit our Sites, we may collect information from you automatically through Cookies.  We also rely on partners to provide many features of our Sites using data about your use of the Sites.  We use Cookies for the following purposes:

• Necessity.  To enable features that are necessary for providing you the services on our Sites, such as keeping you signed in, improving security, and preventing and detecting fraud.
• Preference.  To allow us to remember your preferences and identify you when you return to our Sites.
• Analytics.  To allow us to understand how our Sites are being used, track site performance and content views, and make improvements to the content, products or services.
• Advertising.  To deliver targeted advertising based on your preferences, location, and/or interests across different services and devices and measuring effectiveness of ads.
• Social Media.  To enable the sharing of content from our Sites through social networking and other sites. 

You can modify your browser settings to decline or accept Cookies.  However, in a few cases, some of our Sites’ features may not function as designed. 

If you wish to opt out of our sharing of the data that is gathered when you visit our Site for purposes of targeted digital advertising, we encourage you to visit the Network Advertising Initiative or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements.  Similarly, you can learn about your options to opt out of mobile app tracking by certain advertising networks through your device settings.  You may also visit these websites for more information on how you can opt back in to the sharing of data.  Please note that Millie does not maintain this web tracking data in an identifiable manner.  

Opting out of advertising networks does not necessarily mean that you will not receive advertisements while using our Sites or on other websites.

We do not support Do Not Track functionality.  Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.  You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

7. Children and Privacy

The Sites are intended for a general audience and we do not knowingly collect personal information from children under age 18 through the Sites.  

If you are a parent or guardian and you are aware that a child under age 13 has provided us with personal information without parental consent, please contact us using the information in the Contact Us section.  If we become aware that we have collected personal information from children under age 13 without verification of parental consent, we will take steps to remove that information from our servers.

8. Links to Third Party Sites

Our Sites may contain links to other websites that are not operated by Millie.  We strongly suggest you review their privacy policies.  If any linked website is not owned or controlled by us, we are not responsible for its content or privacy policies, or the practices of the operator of the website or services.

9. International Transfer

Our Sites are operated exclusively in the United States and intended for users located in the United States.  We may transfer, store and use information we collect and maintain about you, including personal information outside of your state, province, country or other governmental jurisdiction.  The data protection laws in the jurisdiction in which we process personal information may differ from those of your jurisdiction, and in certain circumstances, your personal information may be subject to access requests from governments, courts, law enforcement agencies or regulatory agencies in those other jurisdictions.  By using the Sites or providing us with any information, you consent to the transfer and processing of your information, including personal information, in the United States as set forth in this Privacy Policy.  

10. California Privacy Notice

This section of the Privacy Policy applies to any California residents about whom we collect Personal Information (“consumers”). The provisions contained within this section are intended to provide notices in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.

The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of personal information, as well as rights to access, delete, and restrict the sale of certain personal information we collect about them. California residents also have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA. If you are a California resident, you may submit a request to exercise these rights by completing our online webform or by emailing us using the information provided in the Your Privacy Rights section below.  

Consistent with California law, this section does not apply to any data that is already governed by certain other federal or state privacy protections, including but not limited to HIPAA and the California Medica Information Act (“CMIA”).  This section also does not apply to information that Millie may collect in its capacity as a service provider or business associate for another entity.  We encourage you to review the privacy policies and notices of your healthcare provider to learn more information about how it is collected, used, and shared, and what rights you may have regarding that information.

If you are a visually-impaired customer, a customer who has another disability or a customer who seek support in other language, you may access this California Privacy Notice by emailing us at privacy@millieclinic.com. 

a. Personal Information We Collect

For the purposes of this California Privacy Notice, except where a different definition is noted, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.  Personal information does not include publicly available information, information that has been de-identified or aggregated, or other information covered by certain sector-specific privacy laws such as HIPAA and the CMIA.  

Millie collects Personal Information provided by consumers through the Site. Over the last twelve (12) months, we have collected the following categories of personal information from consumers:

• Identifiers, including your first and last name; email address; phone number; physical address; user ID; date of birth; online identifiers as detailed below including IP address or device IDs; and/or other similar identifiers.
• Payment and financial information, including your credit or debit card number and related payment card information; bank account and routing number; and/or other financial information, including to determine eligibility for certain programs and incentives.
• Commercial information, which includes our Services that you have purchased, obtained, or considered; and/or other purchasing or consumer histories, tendencies, and preferences.
• Information relating to Internet activity or other electronic network activity, which includes the information disclosed in Section 1(b) of this Privacy Policy.
• Geolocation information, including your course and precise location generated from your device;
• Audio, electronic, visual, or similar information, which includes voice recordings, photographs, and other user-generated content that you submit to our Sites
• Professional or employment-related information, including your occupation, employer name, and job title.
• Information not listed above and related to characteristics protected under California or federal law, which may include gender or gender identity; race and ethnicity; birth date; information related to employment, and/or medical and health-related information relating to our Services.
• Inferences based on the above information.

b. Personal Information We Collect

Millie may collect, use, or disclose personal information about you for the purposes detailed in Section 2 of this Privacy Policy.

c. Personal Information We Collect

We may collect personal information from the following categories of sources:

• From you, including via our Sites (including the App), in person, telephone, and/or social media
• From your healthcare provider, such as your hospital or other provider
• Through our service providers, such as non-affiliated companies who help us provide Services to you
• From our business partners and others, including those that may promote and/or offer products and services that may be of interest to you

We may supplement the information described above with information we obtain from other sources, including from both online and offline data providers.

d. Who We Share Personal Information With

We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes.  

We do not sell your personal information to third parties, including personal information of minors under 16 years of age.  However, as with nearly every e-commerce company, we do share a limited set of data that is gathered when you visit our Site, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements.  To the extent this activity is interpreted as included in California’s broad definition of “data sale,” we have provided you with opt-out rights as to that activity as described in subsections (e) and (f) below.

e. Your Privacy Rights

If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:  

• Right to Know.  You have the right to, up to twice in a 12-month period, request what personal information we collect, use, disclose, and/or sell, as applicable.
• Right to Delete.  You have the right to request under certain circumstances the deletion of your personal information that is collected by us.
• Right to Opt-Out of Sale.  You have the right to opt-out of the sale of your personal information by a business. However, as noted in subsection (d) above, we do not currently sell any personal information.  We do participate in behavioral ad networks, and to the extent participation in such networks is deemed to be a data sale under the CCPA, we have provided instructions on how you can opt-out in subsection (f) below.
• Right to Non-Discrimination.  You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.  

How to submit a request.  You may exercise any of the rights described in this section by emailing us at privacy@millieclinic.com or writing us at Attn: Privacy Officer, Millie, Inc., 321 Page St, San Francisco, California 94102.

Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA.  We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on.  In order to verify you, you must provide us with your first and last name and email address.  These rights are also subject to various exclusions and exceptions under applicable laws.  

You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf.  The authorized agent may submit a request to exercise these rights by emailing the letter of authorization or power of attorney to privacy@millieclinic.com. 

We currently do not collect household data. If we receive a Right to Know or Right to Delete request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 13, as we do not collect personal information from any person under the age of 13.

We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request for a period covering twelve (12) months and for no more than twice in a twelve-month period.  We reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days. 

Direct marketing by third parties.  We do not disclose personal information to third parties for their own purposes, and we permit you to opt-out of any disclosures of non-identifiable personal information.  However, because California residents have the right to request information regarding such practices under California’s “Shine the Light” Law, please contact us using the information provided at the end of this Policy. You must include your full name, email address and postal address in your email or mail request so that we can verify your California residence and respond.  “Personal information” under this California law means any information that identified, described, or was able to be associated with an individual at the time of disclosure. 

We will continue to update our business practices as direct regulatory guidance becomes available.  For more information on interest-based advertising, please review the rest of this Privacy Policy, including our Cookie Policy.  

f. Notice of Right to Opt-Out

As noted in Sections D and E above, we do not currently sell any personal information.  We do, however, participate in behavioral advertising networks.  To the extent participation in such networks is deemed to be a data sale under the CCPA, we encourage you to visit the Network Advertising Initiative and/or the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements.  You may also fill out our Contact Form on our website to submit a request.

11. Changes to this Privacy Policy

We may change this Privacy Policy from time to time to reflect new services or changes in our data practices or relevant laws.  The “effective date” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes are effective when we post the revised Privacy Policy on the Sites.  If we make any material changes to this Privacy Policy, we will take reasonable measures to notify you via email and/or a prominent notice on our Platform prior to the change becoming effective, and will update the effective date at the top of this Privacy Policy.  You are advised to review this Privacy Policy periodically for any changes. 

2. Contact Us

If you have questions about this Privacy Policy or wish to exercise one of the privacy rights described in this Policy, please contact us in one of the following ways:

Email: privacy@millieclinic.com

Address:‍

Attn: Privacy Officer
Millie, Inc.
321 Page St
San Francisco, California 94102

Telephone:‍

+1 510-495-0310